in accordance with the Code of Administrative Procedure. The appeal has to be submitted to the authority that issued the contested decision within 15 days from the notification of the decision on age assessment.704 Also, as long as an age assessment procedure is pending, the person is considered a child (presumption of minority).705 In practice, the 15-day period may pose an insurmountable obstacle to receiving identification documents proving their age, as in many cases, persons under an age assessment procedure remain restricted in the RIC/CCACs and the appointment of a guardian may take some days. These appeals are in practice examined by the Central RIS. The number of appeals submitted against age assessment decisions in 2024 is not available at the time of writing. Illustratively, last year there was a total of 1,024 decisions issued following an appeal against an initial age assessment (data concerning the period 28/04/2021 until 29/03/2023).706 The persisting administrative contra legem treatment of persons in a pending age assessment procedure as adults was noted also in 2024, with a court decision clarifying that this is a malpractice in contrast to what law stipulates. In a GCR case, a child had been detained for three months in a Pre-Removal Detention Centre together with adults unknown to him, under conditions completely unsuitable for children and with no access to a guardian, given that he was treated as an adult. 707 Another challenge in practice was posed by the significant gaps in medical care and psychosocial support necessary to perform age assessments due to the transition from PHILOS II to IPPOKRATIS program (run by IOM in cooperation with MoMA), exacerbated by the lack of interpretation services for most of the year. As these services were not consistently provided to children in RICs/CACCs, not all children had the opportunity to have their age assessment conducted in a timely manner, while, of course, children continued to grow up thus risking reaching adulthood before ever having had the time to access their rights as children. As per the findings of the Greek Ombudsperson, following inspection visits in CCACs, RICs and CAFTAAS between the second half of 2022 and December 2023, there is a number of problems, obstacles and malfunctions in the implementation of the age assessment process. Indicatively, according to the Ombudsperson’s report, in Samos CCAC, it was found that the psychosocial assessment was not carried out at all due to lack of training of the competent psychosocial team and this stage was being skipped (contrary to the provision of the relevant JMD mentioned above), while the lack of a doctor in the facility of Samos had affected the age assessment, as well, before a doctor was sent from Leros to cover the gap.708 GCR’s findings in Lesvos indicate that in a great number of cases, the age assessment procedure is carried out by two doctors,709 with the initial stage of age assessment being held by the one that is on duty at the RIC. In Lesvos CCAC, furthermore, inadequate implementation of the domestic legislation has been observed,710 as lengthy delays in the age assessment procedures, 711 unlawful use of X-rays, nonacceptance of identification documents, lack of specialised personnel and lack of information regarding the procedure, methods and potential consequences of the age assessment are all forming pieces of a puzzle that a child has to understand alone. Even though there are guardianship mandated persons to care for UASCs during the reporting period, children go through this procedure in the presence a “duty guardian”, appointed when the child’s asylum claim is registered by RIS. At the time of writing (June 2025), an appeal is pending against the age assessment procedure carried out without a guardianship mandated person actually supporting the child throughout the procedure. 712 704 705 706 707 708 709 710 711 712 See Art. 1(9) of JMD 9889/2020. Art. 1(11) of JMD 9889/2020. Response prot.no 472645, 20 October 2023, available in Greek at: https://tinyurl.com/yc4tut2x , 4-5. For more information, see GCR’s Press Release, Children, even alleged ones, are not to be detained. A recent decision of the Administrative Court of Athens safeguards the rights of children and persons under age assessment procedure in Greece”, 2 May 2024, available here. Greek Ombudsperson, The Challenge of Migratory Flows and Refugee Protection Reception Conditions and Procedures, April 2024, available in English and Greek at: https://tinyurl.com/546kmb76, see in particular pp. 150-152 One doctor being a general practitioner and the other a gynecologist. Fenix Humanitarian Legal Aid, Age Assessment Procedures on Lesvos: a Dead Letter, January 2024, available at: https://tinyurl.com/5ek48wfu. At the time of writing (March 2025) this can be up to a month. Information shared within Child Rights Advocacy Network (CRAN). 142